Last Revised – November 25, 2020
This Privacy Statement (“Statement”) outlines how and when The California Dental Association and its affiliated organizations (collectively, “CDA”) collects information about you, and informs you how CDA may use and disclose such information. This Statement applies to your use of the CDA websites located at cda.org, www.tdicinsurance.com, www.cdapresents.com, www.cdafoundation.org, www.smilecrewca.com, and any other websites, mobile applications or online service locations that post a link to this Statement (collectively, the “Sites”). This Statement does not apply to our information collection activities outside of the Sites (unless otherwise stated at the time of collection).
CDA affiliated organizations include The Dentists Insurance Company, TDIC Insurance Solutions, The Dentists Supply Company, the CDA Foundation, the American Dental Association, and the officially chartered component societies of CDA.
- What information do we collect?
We collect information from you through the Sites by “direct means” and “automatic means.” We also collect information about you from other sources.
- By direct means.
We may collect information you provide directly via the Sites. For example, we collect information when you register on one or more of the Sites or otherwise submit information electronically to us through the Sites. We also collect information when you purchase or otherwise obtain or request goods and services online from CDA or its service providers through the Sites. In addition, we collect information when you participate in any of our online features, such as our forums or blogs, submit advertisements to our classified listing or comments to our Sites, or engage in any email correspondence or other communications by means of the Sites.
The information we collect may include Personal Information. “Personal Information” is information that identifies you personally (whether alone or in combination), such as your name, postal address, email address, telephone number, and payment card information. If you are a CDA member at the time of registration, you will be asked to confirm the Personal Information about you in our membership records, including, for example, your name, postal address, email address, American Dental Association member number, California license number, and license type. If you are not a CDA member at the time of registration, you will be asked to submit such Personal Information on our Site registration page.
You may choose to voluntarily submit certain other information to us through the Sites, including Personal Information, but you are solely responsible for your own Personal Information in instances where we have not requested that you submit such information to us.
Note that for purposes of this Statement, your business addresses, business telephone numbers, and other information related to your business that does not identify you as an individual is not considered “Personal Information.” Also, Personal Information once “de-identified” is not subject to this Statement and we may treat it as non-Personal Information and use it without obligation to you except as prohibited by applicable law.
- By automatic means.
We and our service providers may automatically collect certain information about you when you access or use the Sites (“Usage Information”). Such data may include your IP address, device identifier, the type of Internet browser and operating system you are using, the pages and information you accessed on our Sites, the total time spent on our Sites, the domain name of the website from which you linked to our Sites, data regarding network connected hardware, and other information about your use of the Sites. Usage Information helps us understand which parts of our Sites are most popular, where our visitors are going and how much time they spend there. To the extent that we combine Usage Information with your Personal Information, we will treat the combined information as Personal Information under this Statement.
The methods that may be used on the Sites to collect Usage Information include:
- Log Information: Log information is data about your use of the Sites, such as IP address, browser type, internet service provider, referring/exit pages, operating system, date/time stamps, and related data, which is stored in log files.
- Information Collected by Tracking Technologies: Cookies, web beacons (also known as "tracking pixels"), embedded scripts, location-identifying technologies, in-app tracking methods, and other tracking technologies now and hereafter developed (“Tracking Technologies”) may be used to collect information about your interactions with the Sites or emails, including information about your browsing and activity behavior.
- Web Beacons (“Tracking Pixels”)
Web beacons are small graphic images, also known as "internet tags" or "clear gifs," embedded in web pages and email messages. Web beacons may be used to count the number of visitors to the Sites, to monitor how users navigate the Sites, and to count content views.
- Embedded Scripts
An embedded script is programming code designed to collect information about your interactions with the Sites. It is temporarily downloaded onto your device from our web server or a third party with whom we work, is active only while you are connected to the Sites, and deleted or deactivated thereafter.
- Location-identifying Technologies
GPS (global positioning systems) software, geo-filtering, and other location-aware technologies locate (sometimes precisely) you for purposes such as verifying your location and delivering or restricting relevant content based on your location.
- In-App Tracking Methods.
There are a variety of tracking technologies that may be included in mobile apps, and these are not browser-based like cookies and cannot be controlled by browser settings. Some use device identifier, or other identifiers such as “Ad IDs” to associate app user activity to a particular app and to track user activity across apps.
Some information about your use of the Sites and certain Third Party Services (defined below) may be collected using Tracking Technologies across time and services and used by us and third parties for purposes such as to associate different devices you use, and deliver relevant ads and/or other content to you on the Sites and certain Third Party Services.
For further information on Tracking Technologies and your choices regarding them, please see “Third Party Services, Features, and Devices” and “Your Choices” below.
- From offlineand other sources.
CDA may collect more extensive information from you through activities outside of the Sites, the extent of which may depend on your additional activities as a member of CDA, and the extent of additional goods and services you may acquire from or through CDA. Such information may include, but not be limited to, drivers’ and other license numbers, social security numbers, purchasing information and results of surveys in which you choose to participate. We may also collect and retain additional information about you from third parties, such as in connection with providing you with products and services. Some examples of third party sourced information would be information acquired in connection with insurance underwriting decisions or claims adjustment. To the extent we combine such offline or third party sourced information with Personal Information we have collected about you on the Service, we will treat the combined information as Personal Information under this Statement. We are not responsible for the accuracy of any information provided by third parties or third party policies or practices.
- How do we use information?
CDA may use information about you, including your Personal Information, in the following ways:
- to manage our Sites and process your orders for products and services and payments to CDA;
- to respond to your requests for information about CDA and the products and services we make available to you, and provide customer service;
- to send you technical notices, updates, security alerts, information regarding changes to our policies, and support and administrative messages;
- to prevent and address fraud, breach of policies or terms, and threats or harm;
- to monitor and analyze trends, usage, and activities;
- to conduct research, including focus groups and surveys;
- to provide you with advertisements and communications in any form about CDA (and affiliated organizations) and its offerings, products, services, promotions, rewards, and events we think you might be interested in (for information about how to manage these communications and marketing efforts, please see “Your Choices” below);
- for purposes included in or consistent with this Statement; and
- for any other use specified at the time the Personal Information is collected from you or for which we obtain your consent prior to our use of the Personal Information.
- When do we disclose the information we collect?
Except as provided herein, CDA will not sell, rent or otherwise disclose Personal Information about you to unaffiliated third parties.
We may disclose information about you, including Personal Information, under the following circumstances:
- to parties authorized by CDA to host, operate and maintain the Sites and to provide to CDA services consistent with our statements under this Statement and any other applicable agreement between you and CDA;
- to parties engaged by CDA to process information to fulfill purposes authorized by you (such as the shipping to you your purchases or sending to you other materials from CDA);
- to protect the rights, property and safety of CDA, its affiliates, business associates, members and Site visitors or others;
- to relevant parties in the event of a bankruptcy, merger, acquisition, joint venture or other business transaction involving CDA;
- to provide you with products and services and other offerings we make available to you, including CDA direct offerings and offerings by affiliates.
- with our affiliates for internal business purposes;
- with our affiliates, business partners, and other third parties for their own business purposes, including direct marketing purposes (California residents have certain rights set forth in “Your California Privacy Rights” below); and
- with your prior consent or at your direction;
CDA may also disclose information about you, including Personal Information, if required to do so by law, or if CDA believes that such action is necessary to: (a) comply with the law or with a legal process such as a court order, subpoena, search warrant, law enforcement request or other legal process, or (b) protect against misuse or unauthorized use of the Sites or other CDA content to service providers that we retain to carry out activities related to your requests for goods, services or other offerings we may make available to you.
To the extent that CDA is authorized to disclose your Personal Information to a third party in connection with the providing by CDA of any service to you, CDA will take commercially reasonable measures to bind such third party to appropriate contractual obligations of confidentiality. In general, however, CDA cannot be responsible for the failure of unaffiliated third parties to honor their privacy obligations.
Without limiting the foregoing, in our sole discretion, we may share aggregated information which does not identify you or de-identified information about you with third parties or affiliates for any purpose.
- Sweepstakes, Contests, and Promotions
We may offer sweepstakes, contests, surveys, and other promotions (each, a “Promotion”) jointly sponsored or offered by third parties that may require submitting Personal Information. If you voluntarily choose to enter a Promotion, your Personal Information may be disclosed to third parties for administrative purposes and as required by law (e.g., on a winners list). By entering, you agree to the official rules that govern that Promotion, and may, except where prohibited by applicable law, allow the sponsor and/or other parties to use your name, voice and/or likeness in advertising or marketing materials.
- Who is eligible to use and submit Personal Information to the Sites?
The Sites are made available for exclusive use by dentists, those practicing in the allied dental health professions and those professionals with related interests. We do not knowingly collect or accept Personal Information from individuals who have not registered with a Site.
- How can you ask questions about our Statement and access your information?
If you have questions or concerns about this Statement, wish to access or modify your information that you have voluntarily submitted through the Sites or request that we not use such information for a particular purpose, such as receiving communications from CDA, please contact us at:
1201 K Street, 16th Floor
Sacramento, CA 95814
You may also contact us by telephone at 800.232.7645.
We may require additional information from you to allow us to confirm your identity. Please note that we will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
- Third Party Services, Features, and Devices
The Sites may contain content from and links to other websites, locations, platforms, and services operated and owned by unaffiliated organizations (“Third Party Services”), and those Third Party Services may have privacy policies that differ from those expressed here. In addition, our Sites contain features that allow you interact with, connect to, or access our Sites through certain Third Party Services and third party devices (“Third Party Features”). For example, you may interact with a Third Party Service when you apply for a job or “like” or “share” content over social media through our Sites. Remember that third parties may use Tracking Technologies to independently collect information about you and may solicit Personal Information from you. Also, if you use a Third Party Feature, both we and the applicable third party may have access to and use information associated with your use of the Third Party Feature.
Some uses of Tracking Technologies in connection with our Sites may be under the control of unaffiliated entities that CDA retains for the management of certain programs and fulfillment of specific visitor/customer requests. For example, analytics services, such as Google Analytics, may use Tracking Technologies on our Sites to help us analyze your use of the Sites, compile statistic reports on the Sites’ activity, and provide other services relating to Sites activity and Internet usage. Similarly, ad serving services, advertisers, and other third parties may use Tracking Technologies on our Sites and Third Party Services to track your activities across time and services, and tailor ads to you based on your activities, which may include sending you ads on Third Party Services or third party devices after you have left the Sites (“Interest-based Advertising”).
The information collected and stored by third parties, whether through our Sites, a Third Party Service, or a third party device, remains subject to their own policies and practices, including what information they share with us, your choices on their services and devices, and whether they store information in the U.S. or elsewhere. CDA is not responsible for the privacy policies and practices of third parties, and we encourage you to review the privacy policies of such third parties to learn how they process any information you provide to them. To the extent we combine information we receive from third parties with Personal Information we collect directly from you on the Sites, we will treat the combined information as Personal Information under this Statement.
For further information on Tracking Technologies and your choices regarding them, please see “By automatic means” above and “Your Choices” below.
- Your Choices
- Tracking Technologies Generally
With most Internet browsers, you can erase cookies from your device’s hard drive, block cookies or receive a warning before a cookie is stored. Please refer to your browser instructions or help screen to learn more about these functions. Browsers offer different functionalities and options so you may need to set them separately. With respect to our mobile apps, you can stop all collection of information via the app by uninstalling the app. Also, you may be able to exercise specific privacy choices, such as enabling or disabling certain location-based services, by adjusting the permissions in your mobile device. Please be aware, however, that some features and programs of our Sites may be unavailable to you if cookies are erased or blocked, or you disable or remove other tracking technologies.
- Analytics and Advertising Tracking Technologies
You may choose whether to receive Interest-based Advertising by submitting opt outs. Some of the advertisers and service providers that perform advertising-related services for us and our partners may participate in the Digital Advertising Alliance ("DAA") Self-Regulatory Program for Online Behavioral Advertising. To learn more about how you can exercise certain choices regarding Interest-based Advertising, visit http://www.aboutads.info/choices, and http://www.aboutads.info/appchoices for information on the DAA’s opt out program for mobile apps. Some of these companies may also be members of the Network Advertising Initiative (“NAI”). To learn more about the NAI and your opt out options for their members, see http://www.networkadvertising.org/choices/. Please be aware that, even if you are able to opt out of certain kinds of Interest-based Advertising, you may continue to receive other types of ads. Opting out only means that those selected members should no longer deliver certain Interest-based Advertising to you, but does not mean you will no longer receive any targeted content and/or ads (e.g., from other ad networks). CDA is not responsible for effectiveness of, or compliance with, any third-parties’ opt out options or programs or the accuracy of their statements regarding their programs.
- Matched List Ads
Third party websites and applications may display ads from CDA that are targeted to reach people on those websites or applications who are also identified on one of more of CDA’s databases. This is done by matching common factors between CDA’s databases and the databases of these third parties. For instance, we may share your email address with Facebook as part of Facebook’s matched list ad services. If we use Facebook’s matched list ad services, you should be able to hover over the box in the right corner of such a Facebook ad and find out how to opt-out with us from such list. If you opt-out with us from Facebook matched list ad services, we will remove the matching personal information from that Facebook list, however, this will not take effect immediately and if you have multiple emails or other accounts you may have to opt-out separately for each one. We are not responsible for such third parties’ failure to comply with your or our opt-out instructions.
You can “opt-out” from receiving certain promotional communications from CDA, which may prohibit CDA from informing you of certain offerings that may be of interest to you. To opt-out of receiving certain promotional communications (emails and push notifications) from us at any time by (i) for emails, following the instructions as provided in emails to click on the unsubscribe link or by sending an email to us at email@example.com the word UNSUBSCRIBE in the subject field of the email; and (ii) for push notifications or in-app messages, adjusting the permissions in your mobile device. Please note that your opt out is limited to the email address or device used and will not affect subsequent subscriptions or non-promotional communications, such as those about your account, transactions, servicing, or CDA’s ongoing business relations.
- Your California Privacy Rights
California law provides California customers the right to request from CDA certain details about how certain types of their information are shared with third parties, and in some cases, affiliates, for those third parties’ and affiliates own direct marketing purposes. If you would like to request this information, please email your request to firstname.lastname@example.org send a letter to 1201 K Street, 16th Floor Sacramento, CA 95814 (Attention: Legal). Requests must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that CDA is not required to respond to requests made by means other than through the provided email address or mail address.
- California Do Not Track Disclosures
Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no industry consensus as to what site and app operators should do with regard to these signals. Accordingly, we do not monitor or take action with respect to “Do Not Track” signals or other mechanisms. For more information on “Do Not Track,” visit http://www.allaboutdnt.com.
The Sites are intended for a general audience and not directed to children under thirteen (13) years of age. CDA does not intend to collect personal information as defined by the U.S. Children’s Privacy Protection Act (“COPPA”) in a manner that is not permitted by COPPA. If you are a parent or guardian and believe CDA has collected such information in a manner not permitted by COPPA, please email us at email@example.com send a letter to 1201 K Street, 16th Floor Sacramento, CA 95814 (Attention: Legal), and we will remove such data to the extent required by COPPA.
- International Transfer
We are based in the U.S. and the information we and our service providers collect is governed by U.S. law. If you are accessing the Sites from outside of the U.S., please be aware that information collected through the Sites may be transferred to, processed, stored and used in the U.S. Data protection laws in the U.S. may be different from those of your country of residence. Your use of the Sites or provision of any information therefore constitutes your consent to the transfer to and from, processing, usage, sharing and storage of your information, including Personal Information, in the U.S. as set forth in this Statement.
- Changes to this Statement
CDA may revise this Statement from time to time. Any changes will be effective immediately upon posting of the revised Statement. Your continued use of our Sites indicates your consent to the Statement then posted. You should bookmark and periodically review this page to ensure that you are familiar with the most current version of this Statement. You can determine when this Statement was last revised by checking the “Last Revised” legend at the top of the Statement.